UPDATING THE KOGAYON DATA CONFIDENTIALITY POLICY

in the context of new EU regulations: General Regulation (EU) 2016/679 and Directive (EU) 2016/680 which entered into force on 25 May 2018.

Please read the information bellow about the confidentiality policy of KOGAYON.COM website, which is the property of TRANSYLVANIAN CHARMS SRL having J23/2635/17.09.2012, VAT no30421354 and correspondence address 97 Unirii road, Corbeanca, Ilfov county, Romania, Europe, e-mail contact@kogayon.com, tel: 0040 721 240 390, 0033 777732138. For this reason, wherever within the content of this policy, is specified that KOGAYON.COM undertakes obligations and rights, it is understood the owner of the website, TRANSYLVANIAN CHARMS SRL.

  1. 1.   Why do we need your personal data?

KOGAYON uses information from interactions with you and other customers and third parties to achieve its goal of delivering the highest quality products and services.

KOGAYON respects the privacy rights of its online visitors and recognizes the importance of protecting the information collected about them. To that end, we have created procedures to ensure that your personal data is processed in a responsible manner.

This privacy policy informs you about the type of information we collect and how this collection is made; the purposes for which we collect and use this information; your rights and your choices regarding the use of your data by us; the way your data is processed and to whom it can be transferred; and for how long we store your information, etc.

Please read it carefully.

Certain sections of this policy apply expressly to the collection and processing of your personal data when you register to create an account on our online store www.kogayon.com

DEFINITIONS:

The definition of personal data means any information about an identified or identifiable individual. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more specific elements own physical, physiological, genetic, psychic, economic, cultural or social identities.

When we use the term "processing" we refer to any operation or set of operations performed on personal data or personal data sets with or without the use of automated means such as collecting, recording, organizing, structuring, storing, adapting or modifying, extracting, consulting, using, disclosing, disseminating or making available in any other way, alignment or combination, restriction, erasure or destruction.

2. Who controls the data?

KOGAYON establishes the purposes and means of processing your personal data. Having certain legal responsibilities, a data controller is legally responsible for storing and using personal information on a computer or physical files.

Contacts:

SC TRANSYLVANIAN CHRMS SRL, the owner of the brand KOGAYON, with its headquarters in Sos. Unirii, nr. 97, Corbeanca, Ilfov County, Romania, J23 / 2635 / 17.09.2012, CUI 30421354

Contact@kogayon.com

0040 721 240 390

0033 7777 321 38

KOGAYON has not designated a Data Protection Officer. If you have any questions or concerns about privacy or if you have any questions regarding the personal data you have provided us, please contact KOGAYON at any time. For details on how to contact us, please refer to "Contact Details" or send an email directly to contact@kogayon.com

3. What personal data are collected?

All our activities are based on ethical principles and rigorous legal requirements, and we are committed to protecting the privacy of all our site visitors and users of our mobile (mobile) applications. For this reason, the way we collect and store information, including personal data, depends on how our site and related services are used. We do not collect any sensitive data about you.

3.1 Data collected through your interaction with us

Various technologies can be used on our sites and in our mobile (mobile) applications to improve them to make them more usable, efficient and secure. Such technologies may result in the automatic collection of personal data by us or by third parties on our behalf. Examples of such technologies include cookies, flash cookies, and web audience measurement.

From time to time, our site may contain links to and from the sites of our affiliates and our partner networks. If you follow a link to any of these sites, please note that they have their own privacy policies and that we do not accept any responsibility for them. Please refer to these policies before submitting any personal data to these sites.

3.1.1 Visitor Trail Data

When you visit our site, data is sent from your browser to our server. These data allow us to optimize our services and improve your experience on our websites and applications. Data is automatically collected and stored by us or by third parties on our behalf.

We may collect information about your computer for system administration as well as aggregate aggregate information for internal marketing analyzes. These are data about the actions and patterns of our users' browsing may include the following:

· Visitor's IP address

· Date and time of visit

· Referral URL (the site from which the visitor was invited)

· Pages visited and user's route on our site

· Browser information used (type, version, operating system, etc.)

3.1.2 Cookies

Cookies are used on our site. Please read the Cookies Policy to learn more about our use of cookies and the privacy policies of parts from which we use web analytics tools or from which we have built-in extension modules on our sites.

3.1.3 Retargeting technologies

Our site and apps (mobile) use retargeting technologies. This allows us to directly and personally promote our visitors who are already interested in our products and / or our store through our partner sites.

We also work with other companies that use tracking technologies to send advertisements on the Internet on our behalf. These companies could collect information about your visits to our sites or our mobile (mobile) applications, as well as your interaction (interactions) with our communications, including ads.

Retargeting technologies analyze your cookies and show ads based on your previous browsing behavior. For more information on cookies, please refer to section 3.1.2 of this privacy policy.

3.2 Data provided by you

In addition to data collected by automated means (see section 3.1), we also process the data you have provided us with. These include, but are not limited to:

· Personal data that can personally identify you - contact details, name, including your first name and surname, date of marriage, date of acquaintance, photographic image, billing address (s), postal code, date of birth , sex, phone number, e-mail address, credit card and debit card information. If you provide someone else's personal data, please ensure that you have the right to disclose that information.

· Information provided by you at the time of registration to become a member of KOGAYON.

· Information you provide when signing up for a contest or promotion sponsored by KOGAYON

· Information you provide to us through third parties such as Facebook and Instagram

· Information that you upload to our site or which you distribute through our site using our services.

· If you created an online account: the preferences and interests saved in this profile (please read more profile information below).

· If you contact us, we may keep a record of that correspondence.

· If you contact us to report a problem with our site or for technical assistance and / or customer support, we may keep a record of that mail or conversation.

· If we choose to participate in an Alternative Dispute Resolution (ADR) procedure accessible through the Online Litigation (SOL) platform, we may disclose personal data to the European Commission in its capacity as a SOL operator and to any other ADR provider designated to resolve the dispute.

We may also ask you to fill in surveys that we use for research, although you do not have to respond to them. All of this data is characterized by the fact that you yourself provided this information. We use this information for the purposes described in this privacy policy. You may change your personal data at any time or oppose further processing (Please refer to section 7).

4. How are the collected data processed?

When you have registered for a KOGAYON account, we may process your personal data in the following ways:

· To ensure that the site and its content are presented in the most efficient way on your computer.

· For purposes related to your order; for example: to send you notifications about the status of your order or delivery; to respond to your requests, such as answering a question about our products; to help you locate a shop selling KOGAYON products near you; to take over your order; to process your payment card and / or to provide you with customer support. We may use your data to evaluate your creditworthiness, which is why we may be able to call third parties.

· To verify your identity and answer any questions you may have, but also to process your request and provide you with the best service.

· To fulfill our obligations arising from any contracts between you and us.

· To allow you to participate in the interactive elements of our (our) service (s) when choosing to do so.

· To let you know about changes to our services, terms, terms and policies, and / or other administrative information.

· To give you the benefits and services of a KOGAYON account holder.

· To manage and maintain records.

· To manage your KOGAYON account online account.

· To allow you to send emails to others via our "Send to a Friend" feature.

· To allow you to participate in lotteries, contests and other similar promotions and to manage such activities. Some of these activities have additional rules that may contain additional information on how we use and disclose your personal information.

· To personalize your content on our sites to offer you personalized offers.

· To prevent and / or detect any inappropriate use or fraud.

• With your consent, we may contact you directly through your contact details (for example, by regular mail, by e-mail, by SMS, by telephone or by any other electronic means) for marketing, advertising and research purposes market. For example, these messages include information about KOGAYON products, e-commerce activities, special offers and promotions, as well as information about opening local stores and activities in local shops. In order to be able to send you information of interest to you, your general interaction with KOGAYON (such as, but not limited to, your purchasing behavior in online stores and your use of programs by you fidelity, product ratings and reviews, customer contact history, your newsletters / opening results, browsing behavior (web monitoring), newsletters you subscribe to, promotions or events, interactions with and use of mobile apps). We may use your personal data for marketing, advertising, and market research purposes. In section 7, you will find information about your rights, for example, about how to withdraw your consent to the use of the data, or where you can change your personal information.

4.1 When you visit the KOGAYON website, your personal data can be processed in the following ways:

· Content, A / B testing and product browsing analysis

· Traffic source analysis

· Internal search analysis

· Procurement analysis

· Device analysis

· Retargeting marketing

5. Legal basis

When you buy an item from our online store, create an account with us, or terminate any other form of contract with us, we will process your personal personal data for that specific purpose. We may also process your personal data if, for example, you have a question before deciding to enter into a contract with us.

The legal basis on which we will process your personal data is provided in Article 6 (1) (b) of the EU Personal Data (EU) Regulation 2016/679 (GDPR), processing your information necessary for us to perform the contract with you or for the purpose of managing your requests and other similar issues, before concluding a contract.

We may also process your normal personal data under the terms of Article 6 1 f) of the GDPR, unless your rights to privacy and your fundamental freedom prevail over our interests. We have a legitimate interest in processing your personal data (name and email address) for both marketing and analysis purposes. Our legitimate interest is based on your preferences so that we can better customize our offers for you - and ultimately provide you with products and services that better meet your needs and desires. In addition, we have a legitimate interest in processing your personal data for analysis purposes.

6. Disclosure of personal data

One of our basic principles is that we will treat your data carefully and confidentially. If required by law, your data may be disclosed to third parties. We use service providers and persons empowered by the data processor to process data on our behalf. These services include authentication, hosting and maintenance services, analysis services, e-mail services, delivery services, payment management, solvency verification, address and e-mail. These third parties are the persons empowered by the data controller and may process personal data only to the extent necessary for the provision of their services. The data controller is required by contract to treat this information with maximum discretion. It is forbidden to use the data in any way other than the one requested. The necessary steps are taken to ensure that data subjects, including service providers and other persons empowered by the data controller working on behalf of KOGAYON, maintain and protect the confidentiality of your data.

Some of the persons empowered by the data operator are located outside the EU / EEA. As a result, we will transfer your personal data to non-EU / EEA countries. However, we will provide this information only if the receiving party fulfills all the applicable conditions, including:

• The country in question is considered a safe third country.

• The respective supplier will adhere to the European Commission Model Contracts for the transfer of personal data to third countries.

• The respective supplier is certified in accordance with Article 40 of GDPR; or

• The respective provider has a set of Approved Compulsory Corporate Rules.

There may be situations where we disclose to our partners non-personal data in an anonymous form. Such non-personal data may include information about the number of visitors on a site or app (mobile) over a given period of time.

Please note that any information you post or disclose by interacting with KOGAYON (for example, personal data contained in photos, reports, comments, and videos you submit) will become public information and may be available to visitors site, as well as for the general public.

We may disclose your information to the extent that we have a duty to disclose or transmit your personal data to comply with any legal obligation or court order or any structure of the competent authority, or to enforce or enforce our privacy policy and other contracts; or to protect the rights, property or safety of KOGAYON TRANSYLVANIAN CHAMRS SRL to our employees, our clients and others. This includes sharing information with other companies and organizations for the purpose of protecting against fraud and reducing credit risk.

7. Your Rights

If you provide us with personal data through our sites or through other channels, do so freely. If you choose not to provide the requested information, various benefits to customers may not be available. In some cases, only those who have transmitted us the necessary personal data can order products, use certain services, and take advantage of other activities and offers available on our site and in our mobile applications in other ways. We offer different options, depending on the exact circumstances, to help you maintain control over your data. These options may include displaying and editing your online data. It is also possible to unsubscribe from services or delete user accounts or to receive information about our data.

You can access and modify your personal information at any time after you log in to your account at www.kogayon.com and after entering your profile data. Click the "My Profile" or "My Account" button to access your personal information.

If any of the information you provide us changes, for example, if you change your email address or other contact information or if you wish to cancel your registration on our site, please let us know by editing your data on "My Profile" or "My Account" pages or by writing an email mentioning the changes to: contact@kogayon.com

Generally, you have the following rights:

7.1The right to request access to your personal data

You have the right to access some of the personal data you provide to KOGAYON. By writing to contact@kogayon.com, you can request details about the information that you are looking at, which we own and process, including the purposes for which they are used.

You can also access your personal data by logging in to your KOGAYON account at www.kogayon.com and entering your profile data. Click My Account button to access your personal information.

7.2 Right to rectify and / or delete your personal data

You may request the correction, completion, deletion or blocking of your stored personal data. To do so, please send your request to: contact@kogayon.com We will respond to your request to the extent necessary without undue delay upon receipt. If, for any reason, we can not meet your request, we will contact you.

7.3 The right to restrict the processing of your personal data

In special situations, you have the right to restrict the processing of your personal data. To request a restriction, please contact us at contact@kogayon.com

7.4 Right to data portability

You have the right to receive your personal data (only those that concern you) in a structured, commonly used and automatically readable form ("Data Portability"), and you have the right to transfer these data to another data carrier. To request data portability, please contact us at contact@kogayon.com

7.5 The right to oppose the processing of your personal data and to unsubscribe

You have the right to ask us not to process your personal data when the processing is based on a legitimate interest pursued by KOGAYON, for example, for marketing purposes. We will inform you in this privacy policy if we intend to use your data for such purposes or if we intend to disclose your information to third parties for such purposes. You may exercise your right to oppose at any time by contacting us at contact@kogayon.com or in writing at the postal address mentioned at the end of this document.

KOGAYON emails that contain a newsletter or marketing content include the unsubscribe option from receiving such emails following the instructions provided in the e-mail. If you do not want to receive any emails from us, you can click on the unsubscribe hyperlink and we will not send you emails in the future.

As for other types of messages you may receive, such as maintenance or administration related notifications, receiving such messages can only be stopped by deleting your account because such messages are a mandatory part user accounts and the proper use of our sites and applications (mobile). You can request to delete your account by writing an email to contact@kogayon.com

7.6 Right to withdraw your consent at any time

You may at any time withdraw your consent to our processing of personal data. Withdrawal of consent will not, however, affect the legality of consent-based processing prior to its withdrawal. To withdraw your consent, please contact us at contact@kogayon.com

If you wish to withdraw your consent to receive information and promotional offers in general, including by regular mail, by e-mail, by SMS, by telephone or by any other electronic means, you may at any time, by written correspondence with KOGAYON, Data Protection ", or by sending an email to contact@kogayon.com If you have any doubt about your identity, we may ask you to identify yourself.

7.7 Terms and / or limitations of your rights.

Your above-mentioned rights may be subject to conditions or limitations. Therefore, we can not guarantee your right to data portability, as it depends on the specific circumstances of the processing activity.

8. Keep your personal data

KOGAYON will not retain your personal data for a longer period than is necessary for the purposes for which it is processed in the following processing activities:

What personal data will be kept after the 5-year idle period? No personal data will be retained unless required by mandatory local law.

Newsletter - Does not have an account

- Has subscribed to the Newsletter (for example, through online Guest check out channels, etc.)

How do I define an inactive Newsletter subscriber? An Inactive Newsletter Subscriber is a person who has not opened or accessed an email for up to 24 months.

What Personal Information Will be Deleted if a Newsletter Subscriber Is Inactive? All personal data such as: Your name, gender, email address, and product preferences will be deleted. Complete deletion.

When will my personal data be deleted? Personal data will be deleted if a Newsletter Subscriber is idle for up to 24 months.

What personal data will be kept after the 3-year idle period? No Personal Data will be retained unless required by local law.

How we delete personal data KOGAYON and UPDIVISION will manually delete your personal data every quarter. Personal data will be deleted from all IT systems.

How do I define an inactive account holder? An inactive account holder is a person who did not interact with us by making an online purchase despite creating an account, not logging in, not opening or accessing an email for up to 5 years since the last interaction.

What Personal Data Will be Deleted If an Account Holder Is Inactive? All personal data such as: Name, email address, address, postcode, gender, phone number, birthday, date of birth, wish list, purchases. This means Complete deletion.

When will my personal data be deleted? Personal data will be deleted if the account holder is idle for up to five years.

What personal data will be kept after the 5-year period of inactivity? No Personal Data will be retained unless required by local law.

How do I delete my personal data? KOGAYON and UPDIVISION will manually delete your personal data every quarter. Personal data will be deleted from all IT systems.

Acquisition - no account / guest check out A person who made a purchase online or offline without creating an account

How do I define an inactive client? An inactive client is a person who did not interact with us by: online purchase, creating an account, logging in, opening and accessing an email for up to 5 years after the last interaction.

What personal data will be deleted if a client is idle? All personal data, such as: name, email address, postcode, gender, phone number, date of birth, purchases. This means Complete deletion.

When will my personal data be deleted? Personal data will be deleted if a client is idle for up to five years.

What personal data will be kept after the 5-year period of inactivity? No Personal Data will be retained unless required by local law.

How do I delete my personal data? KOGAYON and UPDIVISION will manually delete your personal data every quarter. Personal data will be deleted from all IT systems.

Web Visitors - IP Address A person who visited our site.

How do we define an idle visitor? An inactive visitor is a person who has not visited our 24-month site.

What personal data will be deleted if a client is idle? All data we have collected in connection with the visit to our site, such as:

- Content, A / B testing and product browsing analysis

- Traffic source analysis

- Internal search analysis

- Procurement analysis

- Device analysis

- Marketing Retargeting

When will my personal data be deleted? Personal data will be deleted 25 months after collection.

What personal data will be kept after the 25-month period of inactivity? No Personal Data will be retained unless required by local law.

How do I delete my personal data? Data will be automatically deleted after 25 months.

9. Information security and data integrity

We take appropriate technical and organizational measures to protect personal data against accidental, unlawful destruction, loss, alteration, unauthorized use, disclosure or access, especially when processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.

KOGAYON employs third party party empowered persons to collect and process your personal data. Any KOGAYON third party empowered person will only process your personal data in accordance with KOGAYON's instructions and will be required by law to comply with strict security procedures when handling your personal data.

9.1 Safeguarding information

KOGAYON can call third parties to collect personal information on its behalf. In such cases, these third parties will sign confidentiality and data processing agreements and will receive instructions from KOGAYON to fully comply with the KOGAYON Privacy Policy.

If we have provided you, or if you have chosen your password, which allows you to access certain sections of our site, you are responsible for maintaining the confidentiality of this password. We ask that you do not disclose your password to anyone.

Unfortunately, sending information over the Internet is not entirely secure. While we will do our best to protect your personal data, we can not guarantee the security of your data transmitted to our site; any transmission of information is at your own risk. Once we receive your information, we will use strict procedures and rigorous security features to try to prevent unauthorized access.

9.2 Social Networks

Our site and mobile apps provide you with extension modules from different social networks. If you choose to interact with a social network, your activity on our site or through mobile applications will also be visible on social networks like Facebook and Instagram.

If you have logged in to one of these social networks during your visit to one of our sites or to your mobile (mobile) applications, the social networking site could add this information to your profile. If you interact with one of the social network extension modules, this information will be transferred to the social networking site. If you do not want this data transfer, please log out of the social networking site before joining one of our sites or our mobile apps. We can not prevent this data collection and transfer of information through social network extension modules. Please read the privacy policies of these social networks carefully for detailed information on collecting and transferring personal data, what rights you have, and how to make satisfactory privacy settings.

In addition, to improve your user experience and branding, your data can be passed to a third party (e.g., Facebook) for processing in accordance with data protection and privacy regulations.

Facebook: http://www.facebook.com/about/privacy/

Instagram: https://help.instagram.com/519522125107875

9.3 Geolocation services

Within some of our (mobile) applications, localization services can be used. If you use these applications (mobile), they may receive information about your exact location, such as GPS signals sent by a mobile device or information that can be used to estimate a place. You can enable or disable location services in your device or browser settings.

10. Consequences of non-disclosure of personal data

It is not possible to create a KOGAYON account or make a purchase on www.kogayon.com if you can not provide us with the required information.

11. Contact details

If you have any questions about our privacy policy or your personal data processing, please contact us at

dataprotection@kogayon.com

contact@kogayon.com

You can contact KOGAYON at:

SC TRANSYLVANIAN CHRMS SRL

with its headquarters in Sos. Unirii, nr. 97, Corbeanca, Ilfov County,

0040 721 240 390

0033 7777 321 38

12. Changes to this policy

KOGAYON has committed itself to respecting the fundamental principles of privacy and data protection. We therefore periodically review our privacy policy so that it is up to date and complies with the privacy and protection of personal data. This privacy policy can be changed periodically to keep up with new developments and opportunities related to the Internet and to comply with the applicable law. Any changes that we may make to our privacy policy in the future will be posted on this page and, if applicable, you may be notified by email.

Last Updated: May 2018

 


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